The Department desires to call to the attention of each authorized life company an opinion dated
November 30, 1966 by Deputy Superintendent and General Counsel George K. Bernstein with respect
to the compensation which may be paid to the agent for the writing of individual (a) renewable
or (b) renewable and convertible term policies.

Section 213(3) is specific that a converted policy shall be considered as new life insurance as
follows:

"For the purpose of computing the expense limits, whole life or endowment
insurance preceded by term insurance and converted as of attained age shall be considered
as new life insurance."

However, the statute is not entirely specific as to the commission compensation which may be paid
on renewable term insurance prior to conversion. This question has been considered by Mr. Bernstein
and in the aforesaid opinion he has held that a first year commission may be paid on renewal
only to the extent of the increase in the renewable term premium. With respect to renewal commission
compensation under renewable term policies prior to conversion, the payment of renewal commissions
is limited to the 14 contract years after the first year of insurance, pursuant to Section 213(8).

Each authorized life insurance company should govern its operations consistent with the aforesaid
opinion.